G.R. No. 196874 - Heirs of Spouses Ramiro vs. Spouses Bacaron

On December 29, 2007, JMD’s annual stockholders’ meeting was held in Baguio City, presided by respondent Cecilia Liclican, with co-respondents Norma Isip and Purita Rodriguez, and petitioners Helen Dagdagan, Patrick Pacis, Kenneth Pacis, and Shirley Dominguez in attendance.
Patrick and Kenneth Pacis were denied the right to vote for director positions on the ground that they were not yet registered stockholders, their deceased mother and grandmother still holding legal title to the shares.
After respondents staged a walk‐out, the remaining shareholders (including petitioners) declared a quorum and elected:

Respondents then executed their own “Board Resolution” certifying an alternate set of directors and officers, including Cecilia Liclican as President and two new officers, in direct conflict with the petitioners’ election.

Petitioners filed Civil Case No. 6623-R before RTC Branch 59 seeking nullification of corporate meetings, elections, and acts of respondents and praying for injunctions.
Petitioners, asserting themselves as lawful officers, took possession of corporate properties, represented tenants and collected rents due to JMD.
The case underwent failed mediation and was referred to Judicial Dispute Resolution (JDR) under RTC Branch 7.

On December 15, 2008, petitioners (Dagdagan and Patrick Pacis) filed two Affidavit-Complaints with the Baguio City Prosecutor:

I.S. No. 3011 for the alleged unauthorized withdrawal of ₱852,024.19 from JMD’s Equitable-PCI Bank account and issuance of a ₱200,000 cash check against JMD’s Robinsons Savings Bank account.
I.S. No. 3118 for issuance of Equitable-PCI Bank Check No. 320953 for ₱200,000 to Atty. Francisco Lava, Jr.

The Prosecutor’s Joint Resolution of February 2, 2009 recommended filing of informations for Qualified Theft against Liclican and Isip.

The criminal informations were raffled as Criminal Case Nos. 29175-R (I.S. 3011) and 29176-R (I.S. 3118) before RTC Branch 7 (Judge Mona Lisa V. Tiongson-Tabora).
On March 10, 2009, RTC Branch 7 issued two Orders finding probable cause and directing the issuance of arrest warrants against Liclican and Isip, fixing bail at ₱80,000.

Respondents petitioned the CA (CA-G.R. SP No. 108617) to annul the March 10, 2009 Orders, invoking the prejudicial-question doctrine due to the pending intra-corporate Civil Case No. 6623-R.
On August 30, 2012, the CA annulled and set aside the RTC Orders for grave abuse of discretion, holding that the judge should have suspended criminal proceedings pending resolution of the corporate dispute.
Petitioners’ motion for reconsideration was denied by the CA on January 13, 2013.

Whether Civil Case No. 6623-R constituted a prejudicial question warranting suspension of Criminal Case Nos. 29175-R and 29176-R.
Whether the issuance of the March 10, 2009 RTC Orders finding probable cause and issuing arrest warrants amounted to grave abuse of discretion.